Readiness Review Submission Form - 12.0 Marketing MCO:...

Readiness Review Submission Form - 12.0 Marketing MCO: UnitedHealthcare Community Plan Reviewer: Barbara Molnar

MCO Readiness Review 2014 11/11/2014 of 24

Contract | RFP Reference Contract Requirement Language Review Determination MCO Documentation Title(s)

MCO Policy/Procedure / Document

Section(s)/ Number(s) MCO Page Number(s)

12.2 Marketing and Member Education Plan

12.2.1 The MCO shall develop and implement a plan detailing the marketing and member education activities it will undertake and materials it will create during the contract period, incorporating DHH’s requirements for participation in the MCO Program. The detailed plan must be submitted to DHH for review and approval within thirty (30) calendar days from the date the Contract is signed.

Met UHC addressed the requirement that the MCO develop and implement a plan that details the marketing and member education activities it will undertake and create during the contract period in the Marketing and Member Education Plan. 2015 Marketing and Member Education Plan – DRAFT; page 5 states the plan must be submitted to DHH for review and approval within 30 calendar days from the date the Contract is signed.

2015 Marketing and Member Education Plan – DRAFT (See Sec. 12.2)

Page 1

12.2.2 The MCO shall not begin member education activities prior to the approval of the marketing and member education plan.

Met Addressed in Marketing and Member Education Plan, page 11


Page 11

12.2.3 The MCOs’ plan shall take into consideration projected enrollment levels for equitable coverage of the entire MCO service area. The plan should clearly distinguish between marketing activities and materials and member education activities and materials. The plan shall include, but is not limited to:

Met The Marketing and Member Education Plan addresses the requirement that the MCO’s plan take into consideration projected enrollment levels for equitable coverage of the entire service area. 2015 Marketing and Member Education Plan – DRAFT; page 5 defines and distinguishes Marketing and Member Education separately


Page 10 Page 11

12.2.3.1 Stated marketing and member education goals and strategies;

Met Addressed in Marketing and Member Education Plan, pages 4, 14-23


Page 4 Page 14 Page 21

12.2.3.2 A marketing and member education calendar, which begins with the date of the signed contract, between DHH and the MCO, and runs through the first calendar year of providing services to Medicaid enrollees, that addresses all marketing areas: advertising plans, coverage areas, Web site development and launch plans,

Met Addressed in 2015 UHC Community Outreach Calendar – REVISED DRAFT

2015 UHC Community Outreach Calendar – DRAFT (See Sec. 12.2)

All






printed materials, material distribution plans (including specific locations), outreach activities (health fairs, area events, etc.)

12.2.3.3 A summary of value added benefits to be used in the creation of a plan comparison chart to assist potential enrollees in selecting the MCO that best meets their needs;

Met Address in 2015 Marketing and Member Education Plan – DRAFT, page 37


Pg. 38

12.2.3.4 Distribution methods and schedules for all materials, including media schedules for electronic or print advertising (include date and station or publication) ANN MCGARRY

Met Addressed in 2015 UHC Media Campaign 12-1-14 DRAFT document

2015 UHC Media Campaign 12-1-14 DRAFT (See Sec. 12.2)

All

12.2.3.5 The MCO’s plans for new member outreach, including welcome packets and welcome call;

Met Address in 2015 Marketing and Member Education Plan – DRAFT, page 21


Page 21 Page 22

12.2.3.6 The MCO’s plan to incorporate patient engagement tools such as smart phone-based support programs, mobile applications or text messaging innovations. A smartphone-based support program could include the following features:

Native mobile applications and/or mobile-friendly content that is accessible across a broad range of smartphones;

Consumer-friendly, engaging content that helps keep patients on track with key health appointments and screenings;

Tools to help stratify users by risk profile and direct the higher risk users to State-based or plan-based resources;

Outreach support to educate patients about the mobile tools; and

Reporting and analytics to help the State measure the effectiveness of the smartphone-based support program.

Met Address in 2015 Marketing and Member Education Plan – DRAFT, pages 39-40


Page 39 Page 40






12.2.3.7 How the MCO plans intends to meet the informational needs, relative to marketing (for prospective enrollees) and member education (for current enrollees), for the physical and cultural diversity of the service area. This may include, but is not limited to: a description of provisions for non-English speaking prospective enrollees, interpreter services, alternate communication mechanisms (such as sign language, Braille, audio tapes);

Met Address in 2015 Marketing and Member Education Plan – DRAFT, page 22 as well as in the Member Handbook 12-1-14 DRAFT, page 51

2015 Marketing and Member Education Plan – DRAFT (See Sec. 12.2) Member Handbook 12-1-14 (See Sec. 12.12)

Page 22 Page 51

12.2.3.8 A list of all subcontractors engaged in marketing or member education activities for the MCO;

Met This requirement is addressed in 2015 Marketing and Member Education Plan – DRAFT, page 11 Review Comment: Plan identified only 1 subcontractor; T. Simmons for additional marketing and/or member education activities.


Page 11

12.2.3.9 A copy of the MCO training curriculum for marketing representatives (both internal and subcontractor);

Met Addressed in 2015 Marketing and Education Training PPT as well as in the 2015 Marketing and Education Training, page 25

2015 UHC Training Orientation PPT (See Member Education - Sec. 12.2) 2015 Marketing and Education Training PPT (See Sec. 12.2)

Full PPT Full PPT

12.2.3.10 The MCO’s procedure for monitoring and enforcing compliance with all marketing and member education guidelines, in particular the monitoring of prohibited marketing methods, among internal staff and subcontractors;

Met Addressed in 2015 Marketing and Education Training; slides 105-108 as well as in 2015 Marketing and Member Education Plan – DRAFT

2015 Marketing and Member Education Plan – DRAFT (See Sec. 12.2) 2015 UHC Training Orientation PPT (See Sec. 12.2) 2015 Marketing and Education Training PPT (See Sec. 12.2)

Page 26 Slides 52 – 53 Slides 50 – 69

12.2.3.11 Copies of all marketing and member education materials (print and multimedia) planned for distribution by the MCO or any of its subcontractor’ that are directed at Medicaid eligibles or potential eligibles.

Met The documentation submitted by the plan addressed this requirement..

Diabetes Booklet Sesame Street – Stay Safe Together Sesame Street – Everyday Activities Ideas Asthma Newsletter Building Healthy Communities Hurricane Preparedness Healthy First Steps

Page 7






Pregnancy – First 6 months Pregnancy – Last 3 months Hurricane Preparedness – Web Healthcare Forum Ad Healthy Habits Chart Join for Me Brochure Diabetes Brochure Dental TriFold UHC Plan Brochure Vaccinate Tip Sheet LA Kids Ad LA Provider Ad LA Provider Facing Ad LA Health Smart Sisters Ad Health Smart Sisters Brochure

12.2.3.12 Copies of marketing and member education materials that are 1) currently in concept form, but not yet produced (should include a detailed description) or 2) samples from other states that will be duplicated in a similar manner for the Louisiana Bayou Health population.

Met The documentation submitted by the plan addresses this requirement.

ER Diversion ADHD Brochure Adult – Yearly Checkup Brochure Adult – Health Care Plan Brochure Adult Safe Sex Brochure Asthma Mailer Bipolar brochure Chronic Condition Intervention Community Service Connect Get Moving – Invite Get Moving – Tracker Asthma Diabetes Flu Brochure Safety Tips Breast Cancer Incent Healthy Options Brochure Sesame Street Get Moving Post Partum Behavioral Health Texting Diabetic Testing Mammogram Prenatal Incentive Diabetes Texting Mammogram Consist

Page 7






Diabetes Depression Diabetes Tests ER Diversion Mailer Get Flu Shot Mailer Get Moving Event in a Box Health Rocks – Teens ADHD Health Rocks – Teens Only Body Healthy Kids Need Checkups Immunization Brochure Influenza Kids Need Vaccinations KidsHealth Bookmarker 1 KidsHealth Bookmarker 2 KidsHealth Flyer Lead Poisoning Pregnancy Smoking Cessation Healthy Foods Twitter Obesity Tips Brochure Postpartum Depression Pregnancy Smoking Cessation Brochure Prenatal Appointment Schizophrenia Brochure Sexual Health and Teens Brochure Signs of Depression Brochure Big Bird Decal Taking Charge of Asthma Tweets Card Twitter Card Twitter Poster UHC Pregnant Care 2 UHC Pregnant Care

12.2.3.13 Details of proposed marketing and member education activities and events. All activities must be submitted in the plan using the approved format, Event Submission Calendar;

Met Addressed in 2015 Marketing and Member Education Plan-DRAFT, page 40; 2015 UHC Community Outreach Calendar


Page 40

12.2.3.14 Details regarding the basis it uses for awarding bonuses or increasing the salary of marketing representatives and

Met This requirement is addressed in 2015 Marketing and Member Education Plan-

2015 Marketing and Member Education Plan –DRAFT (See Sec. 12.2)

Page 26






employees involved in marketing; DRAFT, page 26 as well as in 2015 Marketing and Education Training PPT, slide 63

2015 Marketing and Education Training PPT (See Sec. 12.2)

Slide 63

12.2.3.15 Details for supplying current materials to service regions as well as plans to remove outdated materials in public areas;

Met Details for supplying current materials to service regions is addressed in 2015 Marketing and Member Education Plan-DRAFT, page 15. 2015 Marketing and member Education Plan v2; page 15 states outdated materials in public areas are removed by UnitedHealthcare staff.

2015 Marketing and Member Education Plan –DRAFT (See Sec. 12.2) 2015 Marketing and Education Training PPT (See Sec. 12.2)

Page 15 Slide 106

12.2.3.16 The MCO’s protocol for responding to unsolicited direct contact (verbal or written) from a potential member (the MCO is not allowed to engage in marketing encounters with potential members, but Medicaid enrollees may seek out specific MCOs for information).This should include:

Circumstances that will initiate referral to the Enrollment Broker;

Circumstances that will initiate referral to the Medicaid Customer Service Line (toll free #1-888-342-6207);

Circumstances that will terminate the encounter; and

Circumstances that will prompt the MCO to distribute materials to the potential member and a draft of those materials (which must refer all enrollment inquiries to the Enrollment Broker).

Met This requirement is addressed in 2015 Marketing and Member Education Plan-DRAFT, pages 17 & 26


Page 17 Page 26

12.2.3.17 Any changes to the marketing and member education plan or included materials or activities must be submitted to DHH for approval at least thirty (30) days before implementation of the marketing or member

Met This requirement is addressed in 2015 Marketing and Member Education Plan-DRAFT, page 11 as well as in 2015 Marketing and Education Training PPT,


2015 Marketing and Education Training PPT

Page 11

Slides 47 -






education activity, unless the MCO can demonstrate just cause for an abbreviated timeframe.

slide 47-48. (See Sec. 12.2)

48

12.3 Prohibited Marketing Activities

12.3.0 The MCO and its subcontractors are prohibited from in engaging in the following activities:

12.3.1 Marketing directly to Medicaid potential enrollees or MCO prospective enrollees, including persons currently enrolled in Medicaid or other MCOs (including direct mail advertising, “spam”, door-to-door, telephonic, or other “cold call” marketing techniques);

Met This requirement is addressed in 2015 Marketing and Member Education Plan-DRAFT, page 28 as well as in 2015 Marketing and Education Training PPT, slide 51.

2015 Marketing and Member Education Plan – DRAFT (See Sec. 12.2) 2015 Marketing and Education Training PPT (See Sec. 12.2)

Page 28 Slide 51

12.3.2 Asserting that the MCO is endorsed by CMS, the federal or state government or similar entity;



Page 28 Slide 51

12.3.3 Distributing plans and materials or making any statement (written or verbal) that DHH determines to be inaccurate, false, confusing, misleading or intended to defraud members or DHH. This includes statements which mislead or falsely describe covered services, membership or availability of providers and qualifications and skills of providers and assertions the recipient of the communication must enroll in a specific plan in order to obtain or not lose benefits;



Page 29 Slide 51

12.3.4 Portraying competitors or potential competitors in a negative manner;



Page 29 Slide 52

12.3.5 Attaching a Medicaid application and/or Met 2015 Marketing and Member Education Plan – DRAFT Page 29






enrollment form to marketing materials to any member not currently enrolled with the MCO;

This requirement is addressed in 2015 Marketing and Member Education Plan-DRAFT, page 29 as well as in 2015 Marketing and Education Training PPT, slide 52.

(See Sec. 12.2) 2015 Marketing and Education Training PPT (See Sec. 12.2)

Slide 52

12.3.6 Assisting with enrollment or improperly influencing MCO selection;



Page 29 Slide 52

12.3.7 Inducing or accepting a member’s enrollment or disenrollment to any member not currently enrolled with the MCO;



Page 29 Slide 52

12.3.8 Using the seal of the state of Louisiana, DHH’s name, logo or other identifying marks on any materials produced or issued, without the prior written consent of DHH;



Page 29 Slide 52

12.3.9 Distributing marketing information (written or verbal) that implies that joining MCOs or a particular MCO is the only means of preserving Medicaid coverage or that MCOs or a particular MCO is the only provider of Medicaid services and the potential enrollee must enroll in the MCO or MCOs to obtain benefits or not lose benefits;



Page 29 Slide 53

12.3.10 Comparing their MCO to another organization/MCO by name;



Page 29 Slide 53

12.3.11 Sponsoring or attending any marketing or community health activities or events without notifying DHH within the timeframes

Met This requirement is addressed in 2015 Marketing and Member Education Plan-


Page 29






specified in this RFP; DRAFT, page 29 as well as in 2015 Marketing and Education Training PPT, slide 53.


Slide 53

12.3.12 Engaging in any marketing activities, including unsolicited personal contact with a potential enrollee, at an employer-sponsored enrollment event where employee participation is mandated by the employer;



Page 29 Slide 53

12.3.13 Marketing or distributing marketing materials, including member handbooks, and soliciting members in any other manner, inside, at the entrance or within 100 feet of check cashing establishments, public assistance offices, /DCFS eligibility offices for the Supplemental Nutrition Assistance Program (SNAP), FITAP, Medicaid Eligibility Offices and/or certified Medicaid Application Centers. Medicaid Eligibility Office staff or approved DHH agents shall be the only authorized personnel to distribute such materials;



Page 29 Slide 54

12.3.14 Conducting marketing or distributing marketing materials in hospital EDs, , including the ED waiting areas, patient rooms or treatment areas;



Page 29 Slide 54

12.3.15 Copyrighting or releasing any report, graph, chart, picture, or other document produced in whole or in part relating to services provided under this Contract on behalf of the MCO without the prior written consent of DHH;



Page 30 Slide 54

12.3.16 Purchasing or otherwise acquiring or using mailing lists of Medicaid eligibles from third party vendors, including providers and state offices;

Met This requirement is addressed in 2015 Marketing and Member Education Plan-DRAFT, page 30 as well as in 2015 Marketing and Education Training PPT, slide 55


Page 30 Slide 55

12.3.17 Using raffle tickets or event attendance or Met 2015 Marketing and Member Education Plan – DRAFT Page 30






sign-in sheets to develop mailing lists of prospective enrollees;

This requirement is addressed in 2015 Marketing and Member Education Plan-DRAFT, page 30 as well as in 2015 Marketing and Education Training PPT, slide 55.

(See Sec. 12.2) 2015 Marketing and Education Training PPT (See Sec. 12.2)

Slide 55

12.3.18 Charging members for goods or services distributed at events;



Page 30 Slide 55

12.3.19 Charging members a fee for accessing the MCO Web site;



Page 30 Slide 55

12.3.20 Influencing enrollment in conjunction with the sale or offering of any private insurance;



Page 30 Slide 55

12.3.21 Using terms that would influence, mislead or cause potential members to contact the MCO, rather than the DHH-designated Enrollment Broker, for enrollment;



Page 30 Slide 56

12.3.22 Referencing the commercial component of the MCO in any of its Medicaid MCO enrollee marketing materials, if applicable;



Page 30 Slide 56

12.3.23 Using terms in marketing materials such as “choose,” “pick,” “join,” etc. unless the marketing materials include the Enrollment Broker’s contact information.



Page 11 Page 30 Slide 56






12.4 Allowable Marketing Activities

12.4.1 The MCO and its subcontractors shall be permitted to perform the following activities:

12.4.1.1 Distribute general information through mass media (i.e. newspapers, magazines and other periodicals, radio, television, the Internet, public transportation advertising, billboards and other media outlets) in keeping with prohibitions to placement as detailed in this RFP;

Met This requirement is addressed in 2015 Marketing and Member Education Plan-DRAFT, pages 14 & 30 as well as in 2015 Marketing and Education Training PPT, slide 58.



12.4.1.2 Make telephone calls and home visits only to members currently enrolled in the MCO (member education and outreach) for the purpose of educating them about services offered by or available through the MCO;




12.4.1.3 Respond to verbal or written requests for information made by potential members, in keeping with the response plan outlined in the marketing plan approved by DHH prior to response;



Page 30 Slide 58

12.4.1.4 Provide promotional giveaways that exceed the $15.00 value to current members only ;



Page 11 Page 18 Page 30 Slide 58

12.4.1.5 Attend or organize activities that benefit the entire community such as health fairs or other health education and promotion activities. Notification to DHH must be made of the activity and details must be provided about the planned marketing activities using the Event Submission Calendar;

Met Addressed in 2015 Marketing and Member Education Plan – DRAFT, pages 17 & 31 as well as in 2015 Marketing and Education Training PPT, slide 59.



12.4.1.6 Attend activities at a business at the invitation of the entity. Notification to DHH

Met Addressed in 2015 Marketing and


Page 31






must be made of the activity and details must be provided about the planned marketing activities using the Event Submission Calendar;

Member Education Plan – DRAFT, page 31 as well as in 2015 Marketing and Education Training PPT, slide 59


Slide 59

12.4.1.7 Conduct telephone marketing only during incoming calls from potential members. The MCO may return telephone calls to potential members only when requested to do so by the caller. The MCO must utilize the response plan outline in the marketing plan, approved by DHH, during these calls; and

Met Addressed in 2015 Marketing and Member Education Plan – DRAFT, page 31 as well as in 2015 Marketing and Education Training PPT, slide 59


Page 31 Slide 59

12.4.1.8 Send plan-specific materials to potential members at the potential member’s request




12.4.2 In any instance where a MCO allowable activity conflicts with a prohibited activity, the prohibited activity guidance shall be followed.



Page 31 Slide 60

12.5 Marketing and Member Education Materials Approval Process

12.5.1 The MCO must obtain prior written approval from DHH for all marketing and member education materials for potential or current enrollees. This includes, but is not limited to, print, television and radio advertisements; member handbooks, identification cards and provider directories; call scripts for outbound calls or customer service centers; MCO website screen shots; promotional items; brochures; letters and mass mailings and e-mailings. Neither the MCO nor its subcontractors may distribute any MCO marketing or member education materials without DHH consent.

Met Addressed in 2015 Marketing and Member Education Plan – DRAFT, page 31


Page 31

12.5.2 All proposed materials must be submitted Met 2015 Marketing and Member Education Plan – DRAFT Page 31






via email to DHH. Materials must be submitted in PDF format unless an alternative format is approved or requested by DHH.

Addressed in 2015 Marketing and Member Education Plan – DRAFT, page 31

(See Sec. 12.2)

12.5.2.1 Materials submitted as part of the original marketing and member education plan will be considered approved with the approval of the plan if the materials were in final draft form.



Page 31

12.5.3 MCOs must obtain prior written approval for all materials developed by a recognized entity having no association with the MCO, including but not limited to, those developed by a government entity or a nonprofit organization that the MCO wishes to distribute. DHH will only consider materials when submitted by the MCO (not subcontractors).



Page 31

12.5.4 Review Process for Materials

12.5.4.1 DHH will review the submitted marketing and member education materials and either approve, deny or submit changes within thirty (30) days from the date of submission;

12.5.4.2 Once member materials are approved in writing by DHH, the MCO shall submit an electronic version (PDF) of the final printed product, unless otherwise specified by DHH, within ten (10) calendar days from the print date. If DHH requests that original prints be submitted in hard copy, photo copies may not be submitted for the final product. Upon request, the MCO must provide additional original prints of the final product to DHH;

Met Addressed in 2015 Marketing and Member Education Plan – DRAFT, pages 11 & 32


Page 11 Page 32

12.5.4.3 Prior to modifying any approved member material, the MCO shall submit for written approval by DHH, a detailed description of the proposed modification accompanied by a draft of the proposed modification;



Page 11 Page 32

12.5.4.4 DHH reserves the right to require the MCO






to discontinue or modify any marketing or member education materials after approval;

12.5.4.5 MCO materials used for the purpose of marketing and member education, except for the original MCO marketing and member education plan, are deemed approved if a response from DHH is not returned within thirty (30) calendar days following receipt of materials by DHH; and



Page 11 Page 32

12.5.4.6 The MCO must review all marketing and member education materials on an annual basis and revise materials, if necessary, to reflect current practices. Any revisions must be approved by DHH prior to distribution.



Page 32

12.6 Events and Activities Approval Process

12.6.1 The MCO must provide written notice to DHH for all marketing and member education events and activities for potential or current enrollees as well as any community/health education activities that are focused on health care benefits (health fairs or other health education and promotion activities). Notice to DHH may be made prior to the event, or in the form of the Marketing Plan Monthly Report (Appendix BB).



Page 17 Page 32

12.6.2 The MCO must obtain prior written approval from DHH for any activities that include sponsorships.



Page 32

12.6.3 The MCO must obtain prior written approval from DHH for any press or media events or activities.



Page 32

12.6.4 All proposed events and activities, including proposed sponsorships, must be submitted to DHH using Event Submission Calendar.



Page 32

12.6.4.1 Activities and events submitted as part of the original marketing and member

Met Addressed in 2015 Marketing and


Page 33






education plan will be considered approved with the approval of the plan if the activity or event details are complete.

Member Education Plan – DRAFT, page 33

12.6.5 Review Process for Events and Activities

12.6.5.1 DHH will review proposed sponsorship, press or media events and activities and either approve or deny within fourteen (14) business days from the date of submission.

12.6.5.2 In the case where a sponsorship, press or media event or activity arises and approval within the seven (7) business day timeframe is not possible due to the proximity of the event or activity, the MCO may request an expedited approval. DHH reserves the right to deny such requests.



Page 33

12.6.5.3 DHH reserves the right to require the MCO to discontinue or modify any marketing or member education events after approval.

12.6.5.4 Proposed sponsorships, press or media events and activities, except for those included in the original MCO marketing and member education plan, are deemed approved if a response from DHH is not returned within seven (7) business days following notice of event to DHH.



Page 33

12.6.5.5 Any revisions to approved sponsorships, press or media events and activities must be resubmitted for approval by DHH prior to the event or activity using the Event Submission Calendar.



Page 33

12.7 MCO Provider Marketing Guidelines

12.7.1 When conducting any form of marketing in a provider’s office, the MCO must acquire and keep on file the written consent of the provider.

Met Addressed in 2015 Marketing and Member Education Plan – DRAFT, page 33 as well as in the 2015 Marketing and Education Training PPT, slide 65



12.7.2 The MCO may not require its providers to distribute MCO-prepared communications to their patients.

Met Addressed in 2015 Marketing and Member Education Plan – DRAFT, page


Page 33






33 as well as in the 2015 Marketing and Education Training PPT, slide 65.


Slide 65

12.7.3 The MCO may not provide incentives or giveaways to providers to distribute them to MCO members or potential MCO members.

Met Addressed in 2015 Marketing and Member Education Plan – DRAFT, page 33 as well as in the 2015 Marketing and Education Training PPT, slide 65.


Page 33 Slide 65

12.7.4 The MCO may not conduct member education or distribute member education materials in provider offices.




12.7.5 The MCO may not allow providers to solicit enrollment or disenrollment in a MCO, or distribute MCO-specific materials at a marketing activity.



Page 34 Slide 65

12.7.6 The MCO may not provide printed materials with instructions detailing how to change MCOs to members of other MCOs to providers.



Page 12 Page 15 Page 34 Slide 66

12.7.7 The MCO shall instruct participating providers regarding the following communication requirements:



Page 34 Slide 66

12.7.7.1 Participating providers who wish to let their patients know of their affiliations with one or more MCOs must list each MCO with whom they have contracts;



Page 34 Slide 66

12.7.7.2 Participating providers may display and/or distribute health education materials for all contracted MCOs or they may choose not to display and/or distribute for any contracted MCOs. Health education materials must adhere to the following guidance:

Met Addressed in 2015 Marketing and Member Education Plan – DRAFT, page 34 as well as in the 2015 Marketing and Education Training PPT, slide 66-67.


Page 34 Slide 66 Slide 67






Health education posters cannot be larger than 16” X 24”;

Children’s books, donated by MCOs, must be in common areas;

Materials may include the MCOs name, logo, phone number and Web site; and

Providers are not required to distribute and/or display all health education materials provided by each MCO with whom they contract. Providers can choose which items to display as long as they distribute items from each contracted MCO and that the distribution and quantity of items displayed are equitable.

12.7.7.3 Providers may display marketing materials for MCOs provided that appropriate notice is conspicuously and equitably posted, in both size of material and type set, for all MCOs with whom the provider has a contract.



Page 34 Slide 67

12.7.7.4 Providers may display MCO participation stickers, but they must display stickers by all contracted MCOs or choose to not display stickers for any contracted MCOs.



Page 34 Slide 68

12.7.7.5 MCO stickers indicating the provider participates with a particular MCO cannot be larger than 5" x 7” and not indicate anything more than “the health plan or MCO is accepted or welcomed here.”



Page 34 Slide 68

12.7.7.6 Providers may inform their patients of the benefits, services and specialty care services offered through the MCOs in which they participate. However, providers may not recommend one MCO over another MCO, offer patients incentives for selecting



Page 35 Slide 68






one MCO over another, or assist the patient in deciding to select a specific MCO in any way, including but not limited to faxing, using the office phone, or a computer in the office.

12.7.7.7 Upon actual termination of a contract with the MCO, a provider that has contracts with other MCOs may notify their patients of the change in status and the impact of such a change on the patient including the date of the contract termination. Providers must continue to see current patients enrolled in the MCO until the contract is terminated according to all terms and conditions specified in the contract between the provider and the MCO.



Page 35 Slide 69

12.7.7.8 MCOs shall not produce branded materials instructing members on how to change a MCO. The must use DHH provided or approved materials and should refer members directly to the Enrollment Broker for needed assistance.



Page 35 Slide 69

12.8 MCO Marketing Representative Guidelines

12.8.1 All MCO marketing representatives, including subcontractors assigned to marketing, must successfully complete a training program about the basic concepts of Louisiana Medicaid, Bayou Health and the enrollees’ rights and responsibilities relating to enrollment in MCOs and grievance and appeals rights before engaging in direct marketing to potential enrollees.

Met Addressed in 2015 Marketing and Member Education Plan – DRAFT, page 26 as well as in the 2015 Marketing and Education Training PPT, slide 62 and throughout the document

2015 Marketing and Education Training PPT (See Sec. 12.2) 2015 Marketing and Member Education Plan – DRAFT (See Sec. 12.2)

Entire PPT Page 26

12.8.2 The MCO shall ensure that all marketing representatives engage in professional and courteous behavior. The MCO shall not participate, encourage, or accept inappropriate behavior by its marketing representatives, including but not limited to interference with other MCO presentations



Slide 62 Page 26






or talking negatively about other MCOs.

12.8.3 The MCO shall not offer compensation to a marketing representative, including salary increases or bonuses, based solely on an overall increase in MCO enrollment. Compensation may be based on periodic performance evaluations which consider enrollment productivity as one of several performance factors.



Slide 63 Page 26

12.8.4 Sign-on bonuses for marketing representatives are prohibited.



Slide 63 Page 26

12.8.5 The MCO shall keep written documentation of the basis it uses for awarding bonuses or increasing the salary of marketing representatives and employees involved in marketing and make such documentation available for inspection by DHH.



Slide 63 Page 26

12.9 Written Materials Guidelines

12.9.0 The MCO must comply with the following requirements as it relates to all written member materials, regardless of the means of distribution (printed, web, advertising, direct mail, etc.):

Met Addressed in UHC Member Education-Required Materials 11-2014, page 9 as well as in the 2015 Marketing and Member Education Plan – DRAFT, page 35.

UHC Member Education-Required Materials 11-2014 (See Member Education - Sec. 12.11) 2015 Marketing and Member Education Plan - DRAFT

Page 9 Page 35

12.9.1 All member materials must be in a style and reading level that will accommodate the reading skills of MCO Enrollees. In general the writing should be at no higher than a 6.9 grade level, as determined by any one of the indices below, taking into consideration the need to incorporate and explain certain technical or unfamiliar terms to assure accuracy: Flesch – Kincaid; Fry Readability Index; PROSE The Readability Analyst (software developed by Educational Activities, Inc.); Gunning FOG Index; McLaughlin SMOG Index; or Other


UHC Member Education-Required Materials 11-2014 (See Member Education - Sec. 12.11) 2015 Marketing and Member Education Plan – DRAFT (See Sec. 12.2)

Page 9 Page 35






computer generated readability indices accepted by DHH.

12.9.2 All written materials must be clearly legible with a minimum font size of ten-point, preferably twelve-point, with the exception of Member ID cards, and unless otherwise approved by DHH.



Page 9 Page 35

12.9.3 DHH reserves the right to require evidence that written materials for members have been tested against the 6.9 grade reading-level standard.



Page 10 Page 36

12.9.4 If a person making a testimonial or endorsement for a MCO has a financial interest in the company, such fact must be disclosed in the marketing materials.



Page 10 Page 36

12.9.5 All written materials must be in accordance with the DHH “Person First” Policy, Appendix NN.



Page 10 Page 36

12.9.6 The quality of materials used for printed materials shall be, at a minimum, equal to the materials used for printed materials for the MCO’s commercial plans if applicable.



Page 10 Page 36

12.9.7 The MCOs name, mailing address (and physical location, if different) and toll-free number must be prominently displayed on the cover of all multi-paged marketing materials.



Page 10 Page 36

12.9.8 All multi-page written member materials must notify the member that real-time oral interpretation is available for any language

Met Addressed in UHC Member Education-Required Materials 11-2014, page 10 as

UHC Member Education-Required Materials 11-2014 (See Member Education - Sec. 12.11)

Page 10






at no expense to them, and how to access those services;

well as in the 2015 Marketing and Member Education Plan – DRAFT, page 36.


Page 36

12.9.9 All written materials related to MCO and PCP enrollment shall advise potential enrollees to verify with the medical services providers they prefer or have an existing relationship with, that such medical services providers are participating providers of the selected MCO and are available to serve the enrollee.



Page 10 Page 36

12.9.10 Alternative forms of communication must be provided upon request for persons with visual, hearing, speech, physical or developmental disabilities. These alternatives must be provided at no expense to the member.



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12.9.11 Marketing materials must be made available through the MCO’s entire service area. Materials may be customized for specific parishes and populations within the MCOs service area.



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12.9.12 All marketing activities should provide for equitable distribution of materials without bias toward or against any group.



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12.9.13 Marketing materials must accurately reflect general information, which is applicable to the average potential enrollee of the MCO.



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12.9.14 12.9.14.1 12.9.14.2 12.9.14.3

The MCO shall include in all member materials the following: The date of issue; The date of revision; and/or If the prior versions are obsolete.



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12.10 MCO Website Guidelines

12.10.1 The MCO website must include a member-focused section which can be a designated section of the MCO’s general informational website, which is interactive and accessible using mobile devices, and has the capability for bidirectional communications, i.e. members can submit questions and comments to the MCO and receive responses.

Met Addressed in LA MYUHC RRTInfo, pages 1 & 2

myuhc.com portal See document - LA_MyUHC_RRTInfo.pdf

Page 1 Page 2

12.10.2 The MCO website must include general and up-to-date information about its Bayou Health Plan as it relates to the Louisiana Medicaid Program. This may be developed on a page within its existing website to meet these requirements.

Met. Addressed in LA RRT Web 2.0 Deck PPT, slide 1

This occurs on all pages of UHCCommunityPlan.com relate to the Louisiana product. LA RRT Web 2.0 Deck PPT

Webpage Slide 1

12.10.3 The MCO must obtain prior written approval from DHH before updating the website.

Met Addressed in UHC Member Education-Required Materials 11-2014, page 10


Page 10

12.10.4 The MCO must remain compliant with HIPAA privacy and security requirements when providing member eligibility or member identification information on the website.

Met Addressed in UHC Member Education-Required Materials 11-2014, page 10 Reviewer Comment: Though UHC did not cite this section, it is evidence of compliance with this standard

No member eligibility is anywhere on the site. Myuhc.com is a secure member-only portal and complies with HIPAA

No member eligibility on site HIPAA Compliant

12.10.5 The MCO website should, at a minimum, be in compliance with Section 508 of the Americans with Disabilities Act, and meet all standards the Act sets for people with visual impairments and disabilities that make usability a concern. The MCO web site must follow all written marketing guidelines included in this Section.


The entire UHCCommunityPlan.com website is 508 compliant.

508 Compliant

12.10.6 Use of proprietary items that would require a specific browser is not allowed.


N/A N/A






12.10.7 The MCO must provide the following information on its website, and such information shall be easy to find, navigate, and understand by all members:

Met Addressed in UHC Member Education-Required Materials 11-2014, page 11


Page 11

12.10.7.1 The most recent version of the Member Handbook;

Met Addressed in UHC Member Education-Required Materials 11-2014, page 11 as well as in LA RRT Web 2.0 Deck PPT, slide 2

Covered – see PDF - LA RRT Web 2.0 Deck PPT Slide 2

12.10.7.2 Telephone contact information, including a toll-free customer service number prominently displayed and a Telecommunications Device for the Deaf (TDD) number;


Covered – see PDF - LA RRT Web 2.0 Deck PPT Slide 1

12.10.7.3 A searchable list of network providers with a designation of open versus closed panels, shall be updated in real time, upon changes to the network;

Met Addressed in UHC Member Education-Required Materials 11-2014, page 11 as well as in LA RRT Web 2.0 Deck PPT, slide 1 & 2 Reviewer Comment: Accessed searchable provider page

Covered – existing at: http://www.americhoice.com/find_doctor/first.jsp?xplan=uhcla&xtitle=Doctor LA RRT Web 2.0 Deck PPT

Webpage Slide 1 Slide 2

12.10.7.4 The link to the Enrollment Broker’s website (www.bayouhealth.com) and toll free number (1-855-BAYOU-4U, 1-855-229-6848) for questions about enrollment


Covered – see PDF - LA RRT Web 2.0 Deck PPT Slide 2 Slide 3

12.10.7.5 The link to the Medicaid website (www.medicaid.dhh.louisiana.gov) and the toll free number (888-342-6207) for questions about Medicaid eligibility;

Met Addressed in UHC Member Education-Required Materials 11-2014, page 11 Reviewer accessed website via link

Covered – existing at: http://www.uhccommunityplan.com/la/medicaid/community-plan/eligibility.html

Webpage

12.10.7.6 A section for the MCO’s providers that includes contact information, claims submittal information, prior authorization instructions, and a toll-free telephone number;

Met Addressed in UHC Member Education-Required Materials 11-2014, page 11 as well as in LA RRT Web 2.0 Deck PPT, slide 1 Reviewer accessed provider website via link

Covered – existing at: http://www.uhccommunityplan.com/health-professionals/la.html LA RRT Web 2.0 Deck PPT

Webpage Slide 1

12.10.7.7 General customer service information; and Met Covered – see PDF - LA RRT Web 2.0 Deck PPT Slide 1

http://www.americhoice.com/find_doctor/first.jsp?xplan=uhcla&xtitle=Doctor

http://www.americhoice.com/find_doctor/first.jsp?xplan=uhcla&xtitle=Doctor

http://www.uhccommunityplan.com/la/medicaid/community-plan/eligibility.html

http://www.uhccommunityplan.com/la/medicaid/community-plan/eligibility.html

http://www.uhccommunityplan.com/health-professionals/la.html

http://www.uhccommunityplan.com/health-professionals/la.html






Addressed in UHC Member Education-Required Materials 11-2014, page 11 as well as in LA RRT Web 2.0 Deck PPT, slide 1

12.10.7.8 Information on how to file grievances and appeals.

Met Addressed in UHC Member Education-Required Materials 11-2014, page 11 Reviewer accessed site where member could seek info on how to file grievances and appeals. Hidden at bottom of page.

Covered – existing at: http://www.uhccommunityplan.com/la/medicaid/community-plan/member-information.html.

Webpage

http://www.uhccommunityplan.com/la/medicaid/community-plan/member-information.html

http://www.uhccommunityplan.com/la/medicaid/community-plan/member-information.html

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